EN 301 549 V4 is the next edition of Europe's accessibility standard, and its headline change is that web content moves from WCAG 2.1 to WCAG 2.2. A draft, v4.1.0, went out for public comment in November 2025, and the final version, v4.1.1, is expected to be referenced in the EU's Official Journal around October 2026 (ETSI EN 301 549 v4.1.0 draft). Until that reference lands, the current harmonised standard is still v3.2.1, so the legal yardstick today remains WCAG 2.1 Level A and AA. When V4 takes effect, clauses 9, 10, and 11, which cover web, documents, and software, adopt WCAG 2.2 AA. For most website teams that means six new success criteria on top of the 2.1 set: two at Level A and four at Level AA. V4 also rewrites clause 6 for real-time communication and adds two annexes that map the standard to the European Accessibility Act. This guide covers what changes, the six new criteria, and when to act.
What is EN 301 549 V4?
It is the fourth major edition of the EN 301 549 standard, released so far as a draft, v4.1.0, dated November 2025 (ETSI EN 301 549 v4.1.0 draft). ETSI publishes a draft for public comment before a standard is finalised, so v4.1.0 is the version you can read and respond to now, while v4.1.1 will be the finished text. The number matters because of what it points to: EN 301 549 is the standard that gives a "presumption of conformity" with EU accessibility law, and the version referenced in the Official Journal is the one that counts legally.
Today that referenced version is v3.2.1, published in March 2021, which adopts WCAG 2.1 Level A and AA in full for web content (ETSI EN 301 549 v3.2.1). V4 does not change how the standard is built. It updates what it points at. The biggest single update is swapping the WCAG 2.1 baseline for WCAG 2.2.
What's actually changing for the web in EN 301 549 V4?
Clause 9, the web-content clause, moves from WCAG 2.1 to WCAG 2.2. In the draft, clauses 9, 10, and 11 have all been updated to align with WCAG 2.2, so the same shift applies to non-web documents and to software (ETSI EN 301 549 v4.1.0 draft). WCAG 2.2 became a W3C Recommendation on 5 October 2023 and was updated on 12 December 2024 (W3C WCAG 2.2).
WCAG 2.2 added nine success criteria over 2.1 and removed one. Three of the additions sit at Level AAA, which EN 301 549 does not require. That leaves six new criteria at Level A and AA that come into your web scope when V4 is referenced. The removed criterion is 4.1.1 Parsing, marked obsolete in 2.2 because browsers and assistive technology now handle the markup problems it was written for (W3C WCAG 2.2). WCAG 2.2 stays backward compatible: a page that meets 2.2 also meets 2.1.
If you already test against WCAG 2.1 AA, the practical delta is small. You keep everything you do now and add six checks.
What are the six new WCAG 2.2 criteria you'll need to meet?
Here are the six new Level A and AA success criteria that clause 9 will require under V4 (W3C WCAG 2.2):
| Criterion | Level | What it asks for |
|---|---|---|
| 3.2.6 Consistent Help | A | If help is offered (a contact link, a chat, a phone number), it appears in the same relative place across pages |
| 3.3.7 Redundant Entry | A | Don't make someone re-enter information they already gave in the same process; auto-populate it or let them pick it |
| 2.4.11 Focus Not Obscured (Minimum) | AA | When an element gets keyboard focus, it is not entirely hidden behind a sticky header, cookie banner, or other overlay |
| 2.5.7 Dragging Movements | AA | Anything that works by dragging has a single-pointer alternative, such as a tap or click, unless dragging is essential |
| 2.5.8 Target Size (Minimum) | AA | Interactive targets are at least 24 by 24 CSS pixels, or have enough spacing, with listed exceptions |
| 3.3.8 Accessible Authentication (Minimum) | AA | Login doesn't force a cognitive test like solving a puzzle or transcribing characters; allow paste, a password manager, or another route |
Two of these, Target Size and Accessible Authentication, tend to surface real problems on production sites. Tiny icon buttons packed into a toolbar fail 2.5.8. A login flow that blocks paste into the password field, or hides a code in a CAPTCHA a screen-reader user can't solve, fails 3.3.8. Neither is exotic, and both are the kind of thing a design system fixes once and everywhere.
What changes beyond the web in V4?
The largest rewrite outside web content is clause 6. In V4 it broadens from "two-way voice communication" to real-time bidirectional communication, and the requirements for Real-Time Text (RTT) have been significantly revised and extended (ETSI EN 301 549 v4.1.0 draft). This is aimed at "Total Conversation," where voice, real-time text, and video run together, so it mostly affects calling, messaging, and video-conferencing products rather than a typical marketing site or web app.
The draft also adds two annexes, ZA and ZB, that map the standard's technical requirements to the articles of the European Accessibility Act (ETSI EN 301 549 v4.1.0 draft). These are the annexes that make the "presumption of conformity" explicit: meet the mapped requirements, and you are presumed to meet the corresponding legal obligation. V3.2.1 already carried this idea for the Web Accessibility Directive; V4 extends it to the EAA in the same structured way.
When does EN 301 549 V4 take legal effect?
Not on the day ETSI publishes it. A European standard only carries legal weight for accessibility law once it is referenced in the Official Journal of the European Union, and that reference is a separate step handled by the European Commission (European Commission — standards and harmonisation). For V3.2.1, the standard was published in March 2021 and the Official Journal reference followed in August 2021, with an overlap period before the older version stopped applying.
For V4, the current expectation is a reference around October 2026, replacing v3.2.1 (ETSI EN 301 549 v4.1.0 draft). Treat that as a plan, not a fixed date. Draft timelines move, and the comment process can change the text. What is safe to say: today you conform against WCAG 2.1 AA through v3.2.1, and at some point in the 2026 window that baseline steps up to WCAG 2.2 AA.
Does V4 change what you should test today?
Not what you must do, but it changes what's worth doing early. The legal requirement right now is WCAG 2.1 AA. My advice is to test the six new WCAG 2.2 criteria anyway, starting now. They are good practice on their own, several map to bugs real users hit, and doing them early turns the 2026 step-up into a formality instead of a scramble. You would rather find your undersized tap targets on your own schedule than during an audit.
A short plan that ages well: keep meeting WCAG 2.1 AA, add the six 2.2 checks to your test pass, and note in your accessibility statement which version you tested against and when. When the Official Journal reference lands, you update the version line and confirm the six criteria you already handled. Our WCAG checklist covers the full 2.2 AA set so you can work the new items in alongside the ones you already run.
One honest limit: an automated scan will catch some of these and not others. A tool can measure target size and flag a login field that blocks paste. It cannot judge whether your help link is in a consistent place, or whether a focused element is meaningfully visible behind a sticky header. Automated testing identifies roughly 30 to 57% of issues depending on how you count, and the rest needs a person (Deque). The new criteria don't change that split.
Frequently asked questions
What is EN 301 549 V4?
It is the next edition of the EU accessibility standard EN 301 549, released as draft v4.1.0 in November 2025. Its main change for web content is adopting WCAG 2.2 Level A and AA in place of WCAG 2.1. The final text is expected to be v4.1.1.
When does EN 301 549 V4 become the harmonised standard?
It is expected to be referenced in the Official Journal of the EU around October 2026, replacing v3.2.1. A standard only carries legal weight once that reference is published, so until then v3.2.1 and WCAG 2.1 AA remain the yardstick. Treat the date as an expectation, not a fixed deadline.
How is EN 301 549 V4 different from v3.2.1?
The structure is the same, but the WCAG baseline for clauses 9, 10, and 11 moves from WCAG 2.1 to WCAG 2.2. V4 also rewrites clause 6 for real-time communication, revises Real-Time Text, and adds annexes ZA and ZB mapping the standard to the European Accessibility Act.
What new WCAG 2.2 criteria will EN 301 549 V4 require?
Six at Level A and AA: Consistent Help (A), Redundant Entry (A), Focus Not Obscured Minimum (AA), Dragging Movements (AA), Target Size Minimum (AA), and Accessible Authentication Minimum (AA). WCAG 2.2 also removes the old 4.1.1 Parsing criterion.
Do I need to test WCAG 2.2 now?
Legally, no. The referenced standard is still v3.2.1, so WCAG 2.1 AA is the current requirement. It is worth adding the six new checks early, though, because several map to problems real users hit and it makes the eventual switch to V4 a small update rather than a rush.
Get ahead of the WCAG 2.2 baseline
The switch to WCAG 2.2 in EN 301 549 V4 is a manageable delta if you start on the six new criteria before the Official Journal reference forces the issue. Run a free scan to clear the machine-detectable checks on your key pages, including target size and paste-blocked logins, then work the manual 2.2 criteria a scanner cannot judge and record each result. You will walk into the V4 transition with evidence instead of a guess.
Pavel Charkasau, founder, wcagc.com. Last updated 17 July 2026.
Sources
- Draft EN 301 549 V4.1.0 (2025-11), ETSI — the draft fourth edition; clauses 9, 10, and 11 aligned with WCAG 2.2, clause 6 broadened to real-time bidirectional communication with revised Real-Time Text, and new annexes ZA/ZB mapping to the European Accessibility Act. Accessed 17 July 2026.
- EN 301 549 v3.2.1 (2021-03), ETSI — the current harmonised standard adopting WCAG 2.1 Level A and AA for web content. Accessed 17 July 2026.
- Web Content Accessibility Guidelines (WCAG) 2.2, W3C — Recommendation dated 5 October 2023, updated 12 December 2024; the nine added success criteria, their conformance levels, and the removal of 4.1.1 Parsing. Accessed 17 July 2026.
- Web Accessibility Directive: standards and harmonisation, European Commission — how a European standard gains legal effect through an Official Journal reference. Accessed 17 July 2026.
- Automated testing identifies 57% of accessibility issues, Deque — automated coverage figures across more than 2,000 audits. Accessed 17 July 2026.